Credit Card Reapplication Denied - Adverse Action?
Answer by Dan Persfull, BOL Guru Guru Bio
Question: If we close a credit card due to delinquent status and then ask the borrower to reapply to reopen their account and they do not qualify upon the new application, do we send an adverse action notice? Would we mark the spot "we regret that it is necessary to terminate your line of credit"?
Answer: If you close the account for delinquency then no adverse action notice is required. However, if they reapply to have the account reopened and you deny that request then you owe them an adverse action notice with the reason(s) you denied the request.
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